ICE Futures U.S. submitted two certifications to the Commodity Futures Trading Commission on May 13, 2019, establishing rules for proposed daily and monthly bitcoin futures contracts designed to settle through delivery of bitcoin rather than a cash index payment.
Submissions 19-160 and 19-161 placed the products inside the exchange and clearing infrastructure of Intercontinental Exchange. The contracts were to trade on ICE Futures U.S., clear through registered derivatives clearing organization ICE Clear U.S., and use Bakkt Trust Company LLC as the warehouse through which bitcoin would be held and transferred at settlement.
The filings constituted exchange self-certifications under Section 5c(c)(1) of the Commodity Exchange Act and CFTC Regulation 40.2. They were not orders approving Bakkt, findings that its custody operation was licensed, or announcements that live trading had begun.
What the contracts would do
Each daily or monthly contract represented one bitcoin and was quoted in U.S. dollars. The minimum price movement was specified as $2.50 per contract for central-order-book transactions and $0.01 for block trades. ICE proposed listing as many as 70 consecutive exchange business days for the daily product and 12 consecutive calendar months for the monthly product.
Physical settlement was the defining feature. A clearing member holding a short position through expiration would have to deliver bitcoin, while the corresponding long would receive it. The Bakkt Warehouse would record deposited bitcoin on its internal books and transfer ownership between customer accounts under instructions from ICE Clear U.S. The filing stated that the warehouse could not use bitcoin deposited for these contracts for its own purposes.
That structure distinguished the proposal from a contract that merely calculated a dollar payment from a reference price. It also joined futures trading, clearing, margin, custody and final delivery in one institutional arrangement. ICE said initial and variation margin would follow its clearing model, with margin obligations satisfied in cash or other eligible collateral rather than bitcoin.
The unresolved regulatory dependency
The May 13 record included an important condition: Bakkt Trust Company had applied to the New York State Department of Financial Services for a limited-purpose trust-company license. ICE stated that trading would not commence until relevant ICE Clear U.S. rule amendments became effective and the warehouse obtained that license.
The distinction matters. Self-certification places responsibility on a designated contract market to certify that its rules comply with the Commodity Exchange Act and CFTC regulations. It does not convert a pending state custody application into an issued license. CFTC guidance then in effect also emphasized surveillance, large-trader reporting, clearing risk and coordination with commission staff for virtual-currency derivatives.
ICE proposed an initial reportable level of five contracts and a position limit of 100,000 contracts. Those were proposed market-control parameters, not trading-volume forecasts or evidence of investor demand.
Market context and uncertainty
The filing arrived during a sharp bitcoin rally. A contemporaneous Reuters report published on May 14 said bitcoin crossed $8,000 late on May 13, its highest level since July 2018. Reuters did not identify a single venue or a formal daily closing methodology for that threshold, so it should be treated as an intraday market observation rather than a universal close.
The timing does not establish that the ICE filings caused the rally. Bitcoin traded continuously across fragmented venues, and the contemporaneous reporting said there was no clear fundamental explanation for the move. The defensible interpretation is narrower: ICE advanced a detailed institutional market-structure proposal while interest in bitcoin was visibly recovering.
Later context
On June 13, 2019, ICE announced that user-acceptance testing would begin on July 22, 2019. That later notice said trading was expected in the second half of 2019 and remained subject to regulatory approval of the Bakkt Warehouse. It confirms that the May 13 filings were a development milestone, not a completed launch. This reconstructed record preserves that event-date distinction.
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